Williams v. Community Solutions, Inc., 932 F. Supp. 2d 323

Doucette and Villafane sue State Defendants for sexual abuse/harassment at Drapelick Center, a state-contracted residential facility; Williams dismissed from suit against State Defendants, leaving Doucette and Villafane’s claims.
Drapelick Center is run by CSI under contract with the State; alleged abuse involves staff Ball and Lester and an investigatory/oversight process by DOC and DPS.
Counts asserted include: 1983 Eighth Amendment (Count One), Fifth Amendment (Count Two), 1981/1983 discrimination (Count Three), Fourth Amendment bodily privacy (Count Four), assault and battery (Count Five), negligent hiring/retention/supervision (Count Six), intentional infliction of emotional distress (Count Seven), negligent infliction of emotional distress (Count Eight).
State Defendants moved to dismiss under Rule 12(b)(6); Williams voluntarily dismissed, leaving Doucette and Villafane against State Defendants; court grants dismissal as to those claims.
Court applies Twombly/Iqbal plausibility standard and limits review to pleadings and attached/ incorporated materials.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Doucette and Villafane state a viable Eighth Amendment claim.	Doucette and Villafane allege deliberate indifference by State Defendants.	State Defendants contend allegations are insufficiently serious.	No; claims do not show sufficiently serious deprivation; Count One dismissed.
Whether Count Two Fifth Amendment claim is viable.	Plaintiffs allege due process/cruelty claims from threats of confinement.	No life, liberty, or property deprivation; Fifth Amendment not applicable as inmates.	Count Two dismissed.
Whether Count Four Fourth Amendment bodily privacy claims against DOC Defendants survive.	Belief that bodily privacy rights were violated by staff actions.	No actual search or intrusion described; Fourth Amendment not applicable to this context.	Count Four dismissed.
Whether Lindley and DOC Defendants can be liable for assault and battery (Count Five).	Lindley aided, conspired, or acted via respondeat superior.	No substantial evidence of aiding/abetting, conspiracy, or scope of employment.	Count Five dismissed; no civil conspiracy; no respondeat superior liability established.
Whether Count Eight NIED is viable given state immunity.	State Defendants caused emotional distress through negligence.	Statutory immunity under Conn. Gen. Stat. § 4-165 bars negligent actions.	Count Eight dismissed due to immunity.

Farmer v. Brennan, 511 U.S. 825 (1994) (Eighth Amendment deliberate indifference standard)
Boddie v. Schnieder, 105 F.3d 857 (2d Cir.1997) (sexual abuse by corrections officer analyzed under Eighth Amendment)
Twombly v. Bell Atlantic Corp., 550 U.S. 544 (2007) (pleading requires plausible grounds for relief)
Iqbal v. Ashcroft, 556 U.S. 662 (2009) (narrowing of pleading standard to plausible claims)
Blyden v. Mancusi, 186 F.3d 252 (2d Cir.1999) (supervisor liability requires underlying constitutional deprivation)
Miller v. Egan, 265 Conn. 301 (2003) (state employee immunity for negligent conduct within scope of employment)
Goord v. Goord, 430 F.3d 652 (2d Cir.2005) (Fourth Amendment privacy interests in prison context)